The Goods and Services Tax (GST) regime mandates annual reporting for registered taxpayers to ensure transparency, accurate tax compliance, and proper reconciliation of sales, purchases, and tax liabilities. For this purpose, GSTR-9 and GSTR-9C are two critical forms that every applicable taxpayer must understand. This guide provides a comprehensive overview of these annual GST returns, their applicability, filing process, and key compliance updates.

  • GSTR-9: ANNUAL GST RETURN

What is GSTR-9?
GSTR-9 is the annual return under GST that consolidates details of all outward supplies, inward supplies, and GST paid during a financial year. While it summarizes data reported in GSTR-1, GSTR-2B, and GSTR-3B, filing GSTR-9 requires thorough reconciliation of tax liability and Input Tax Credit (ITC) to ensure correctness.
Due Date: Typically, 31st December of the year following the relevant financial year.

Who Must File GSTR-9?
All regular GST-registered taxpayers whose annual turnover exceeds ₹2 crore are required to file GSTR-9.

Exemptions include:
  • Composition scheme taxpayers (file GSTR-9A/GSTR-4)
  • Casual taxable persons
  • Input service distributors
  • Non-resident taxable persons
  • Taxpayers paying TDS (Sec. 51) or collecting TCS (Sec. 52)
Contents of GSTR-9
The form comprises 6 parts and 19 sections, capturing:
  • Annual sales (taxable and non-taxable supplies)
  • Purchases and ITC availed (inputs, input services, capital goods)
  • ITC reversals due to ineligibility

Filing Process Simplified
  • Ensure all GSTR-1 and GSTR-3B returns are filed for the year.
  • Conduct detailed reconciliation of ITC and sales.
  • Address discrepancies with vendors or customers.
  • Disclose reconciled data via the GST offline tool or cloud-based software.
  • Pay any short tax dues or adjust excess ITC via DRC-03.
  • File GSTR-9 on the GST portal.

Turnover Thresholds & Late Fees
As per Notification No. 14/2023-CT dated May 10, 2023

FORMTurnoverFee per Day (CGST + SGST)Max Fee
GSTR 9Up to ₹5 Cr₹50 (₹25 each)₹10,000
₹5–20 Cr₹100 (₹50 each)₹20,000

Above ₹20 Cr₹200 (₹100 each)₹30,000
GSTR 9C
₹200/day (from later date*) 0.5% of State turnover


RECENT UPDATES
  • From July 2025, filing of GSTR-3B is restricted if three years have passed since the due date.
  • In Jan 2025, GSTN issued Circular No. 246/03/2025-GST clarifying late fee calculation for GSTR-9C under Section 47(2).

Importance of GSTR-9: Filing GSTR-9 ensures accurate reporting, reconciles ITC claims, and minimizes the risk of penalties.

  • DOCUMENTS REQUIRED FOR FILING GSTR-9 & 9C

Before initiating the annual return filing process, taxpayers should ensure all relevant records and data are readily available. Proper documentation helps in accurate reconciliation and smooth filing.

1. General Documents

  • GST Registration Certificate (GSTIN, Legal & Trade Name)
  • Audited financial statements (Balance Sheet, Profit & Loss A/c, and Trial Balance)
  • Summary of turnover as per books of accounts
  • Details of tax payments made during the year

2. Return-Related Data

  • GSTR-1 (Details of outward supplies)
  • GSTR-3B (Monthly/Quarterly tax payment summary)
  • GSTR-2B (Auto-drafted Input Tax Credit statement)
  • E-way bill summary (for verification of outward supply details)

3. Input Tax Credit (ITC) Records

  • ITC ledger and purchase register
  • Details of ineligible ITC, reversals under Rule 42/43
  • Reconciliation of ITC as per books vs. GSTR-2B
  • Vendor-wise reconciliation for unmatched credits

4. Turnover & Tax Liability Reconciliation

  • Reconciliation of turnover between books, GSTR-1, and GSTR-3B
  • Details of adjustments, credit notes, debit notes, and advances
  • Tax rate-wise summary of outward supplies (5%, 12%, 18%, 28%)
  • Details of exempt, nil-rated, and non-GST supplies

5. Other Supporting Documents

  • Details of DRC-03 payments (if any shortfall was paid)
  • Expense ledgers used to compute ITC reversals
  • HSN-wise summary of goods and services
  • Any audit observations or rectifications done during the year

6. For GSTR-9C (Reconciliation Statement)

  • Audited financial statements (mandatory for reconciliation)
  • Trial balance or segment-wise turnover statements
  • Management representation or self-certification by taxpayer
  • Adjustments made between audited turnover and GSTR-9 data

  • GSTR-9C: ANNUAL GST RECONCILIATION STATEMENT

What is GSTR-9C?
GSTR-9C is a self-certified annual reconciliation statement required for taxpayers with an aggregate turnover exceeding ₹5 crore. It reconciles:
  • Figures reported in GSTR-9 (annual return)
  • Figures reported in audited financial statements

Discrepancies in turnover, tax liability, or ITC must be disclosed with explanations. Multiple GSTR-9C forms may be filed if multiple GSTINs exist under the same PAN.
Due Date : Same as GSTR-9—usually 31st December of the following financial year.

Applicability & Exemptions

  • Mandatory for taxpayers with turnover above ₹5 crore.
  • Exemptions include foreign airlines and non-resident OIDAR service providers.
  • Small taxpayers (turnover < ₹2 crore for FY 2023-24) may be exempted from filing GSTR-9/9C.

Contents and Structure of GSTR-9C
Part A – Reconciliation Statement

  • Part I: Basic details (GSTIN, PAN, FY, legal/trade name)
  • Part II: Reconciliation of turnover in audited accounts vs. GSTR-9
  • Part III: Reconciliation of GST liability and taxes paid
  • Part IV: Reconciliation of ITC availed and utilized, including reversals

Part B – Verification/Self-Certification

  • Taxpayers must self-certify the reconciliation statement.
  • CA/CMA certification is no longer mandatory.

Filing Requirements

  • All monthly/quarterly returns (GSTR-1, GSTR-3B, and GSTR-9) must be filed before submitting GSTR-9C.
  • Any additional tax liability can be paid via DRC-03, using the electronic cash ledger.

RECENT UPDATES
  • Late fees exceeding GSTR-9 fees for FY 2017-18 to 2022-23 will be waived if GSTR-9C is filed by 31st March 2025.
  • Relaxations provided for small taxpayers and certain non-resident service providers.

Importance of GSTR-9C: Helps reconcile GST reporting with audited accounts, ensures transparency, and prevents penalties.

  • KEY DIFFERENCES BETWEEN GSTR-9 & GSTR-9C

FeatureGSTR-9GSTR-9C
ApplicabilityTurnover > ₹2 croreTurnover > ₹5 crore
NatureAnnual returnReconciliation statement
Data SourceGSTR-1, GSTR-3B, GSTR-2BGSTR-9 + audited financials
CertificationSelf-filedSelf-certified (CA/CMA optional)
ObjectiveConsolidates annual GST dataReconciles GST data with accounts
Due Date31st Dec (following FY)Same as GSTR-9


In essence, GSTR-9 summarizes GST activity for the year, while GSTR-9C verifies its accuracy against audited accounts. Filing both ensures compliance, accurate ITC claims, and transparency.

  • CONSEQUENCES OF NON-FILING / LATE FILING

Failure to file GSTR-9 or GSTR-9C within the prescribed due date attracts late fees, interest, and potential compliance actions under the GST Act.

1. Late Fees under Section 47(2)
  • ₹100 per day under CGST + ₹100 per day under SGST (₹200 per day total).
  • GSTR-9 Late Fee: Levied from due date (31st Dec) until actual filing date.
  • GSTR-9C Late Fee: Levied from the LATER of:
- Due date of annual return (31st Dec), OR
- Date of filing GSTR-9
- ...until date of filing GSTR-9C
  • Subject to a maximum of 0.5% of total turnover in the State/UT.
  • For smaller taxpayers, the GST Council has provided concessional rates as shown in the late fee table above.

2. Interest on Delayed Payment
  • Interest @ 18% per annum on unpaid tax liability from the due date until the actual date of payment.

3. Blocking of E-Way Bill Generation
  • Non-filing of returns for a continuous period may lead to blocking of e-way bill generation, affecting business operations and goods movement.

4. Departmental Notices & Scrutiny
  • Consistent delays or non-filing may trigger scrutiny notices or audit proceedings under Sections 61 and 65 of the CGST Act.

5. Risk of ITC Reversal or Denial
  • Non-filing of annual returns may cause mismatch in ITC claims, leading to reversal or ineligibility of credits.

Noted : Non-filing not only attracts monetary penalties but also increases the risk of compliance scrutiny and reputational issues.

  • Important FAQs – GSTR-9 & GSTR-9C for FY 2024-25

Q1: When will GSTR-9/9C for FY 2024-25 be enabled?

GSTR-9/9C is enabled automatically once all GSTR-1 and GSTR-3B returns for FY 2024-25 are filed. If any return is pending, GSTR-9 cannot be accessed.

Q2: How are Tables 4, 5, 6, 8, and 9 auto-populated?

Relevant cells are auto-filled based on filed returns (GSTR-1/1A/IFF, GSTR-2B, GSTR-3B). Amendments via GSTR-1A or IFF for FY 2024-25 also reflect in these tables.

Q3: What is Table 8A and how is it populated?

Table 8A captures inward supplies for FY 2024-25 from GSTR-2B:
  • Includes invoices of FY 2024-25 reported between April–October 2025.
  • Excludes FY 2023-24 invoices.
  • Late invoices added by suppliers in the next FY (April–Oct 2025) appear in 8A after filing GSTR-3B.

Q4: How should ITC be reported across FYs?

  • Claim, reversal, reclaim within FY 2024-25: Claim → Table 6B; Reversal → Table 7; Reclaim → Table 6H.
  • ITC of FY 2023-24 claimed in FY 2024-25: Table 6A1.
  • ITC of FY 2024-25 reclaimed in FY 2025-26: Not under Rule 37/37A → Table 13 (FY 2024-25) and Table 6A1 (FY 2025-26)
    Under Rule 37/37A → Table 6H (FY 2025-26) only

Q5: What is Table 8C?

Table 8C contains missed ITC of FY 2024-25 claimed for the first time in FY 2025-26. It excludes ITC claimed & reversed in FY 2024-25 and reclaimed in FY 2025-26.

Q6: How are imported goods ITC reported?

  • IGST on import → Table 8G (FY 2024-25)
  • ITC claimed next FY → Table 8H1 (FY 2024-25) and Table 13
  • Not reported in Table 6E; difference in Table 8I → Nil

Q7: How is Tax Payable (Table 9) auto-populated?

Table 9 captures net tax liability from GSTR-3B (Table 6.1). Positive net liability is auto-populated; negative is not. Editable for adjustments.

Q8: Any changes in Table 6M, 12, 13, or 17?

  • Table 6M: Label updated; ITC claimed through ITC 01/02/02A reported here.
  • Table 12: ITC of FY 2024-25 reversed in next FY.
  • Table 13: ITC of FY 2024-25 availed in next FY.
  • Table 17: New Excel sheet provided for HSN details from Table 12 (GSTR-1/1A) for easy reporting.

Q9: Is the concessional 65% tax rate still applicable?

No. From FY 2024-25, the 65% checkbox is removed from Tables 17 & 18 in both online and offline tools.

KEY TAKEAWAYS

The filing of GST Annual Returns (GSTR-9 and GSTR-9C) for FY 2024-25 is a critical year-end compliance requirement. With revised ITC disclosures and strict filing timelines, it is essential for taxpayers to begin reconciliation well in advance of the December deadline.

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DISCLAIMER
The information contained in this document is prepared by R.J. Soni & Associates and TaxOSmart LLP (hereinafter referred to as RJSA) for information purpose only. It does not constitute any legal advice or tax advice. In no way, this document should be treated as a marketing material or efforts to solicit a client. While we have made every attempt to ensure that the information contained in this document is true, RJSA, its partners and/or any of its employees make no claims / guarantee about its accuracy, completeness, or up-to-date character, or warranty, express or implied, including the warranty of opinions expressed for a particular purpose, or assume any liability or responsibility for the accuracy, completeness, or usefulness of any information available from this document.